What happens on the Dolores River below McPhee Reservoir is always closely monitored by the Dolores Water Conservancy District board and its general manager.

That’s because federal land management protections downstream of the dam could require additional water to be released into the river for environmental purposes, such as helping native fish.

National “wild and scenic river” designations – a type of use-restrictive “wilderness area” for pristine waterways – come with a federally reserved water right. But reservoir managers object to the water right because it threatens irrigation supply.

DWCD is no exception, and they’ve formally protested a newly released San Juan Public Lands management plan that strengthens a formula for Dolores River protection in favor of native fish.

No parts of the Dolores River are designated as a “wild and scenic river,” which would require Congressional approval.

However, for an 80-mile stretch from below McPhee dam to Bedrock, the Dolores River is considered “preliminarily suitable” for a WSR designation by the forest service and BLM.

The suitability status means the section is strictly managed to protect its current natural qualities and native fish populations in case it becomes a WSR some day.

“Suitability for Wild and Scenic is cropping up below us, and if it becomes an official designation, there could be mandatory federal water requirements,” said Mike Preston, DWCD general manager.

In an Oct. 10 protest letter to federal land agencies, the DWCD objects to the U.S. Fish and Wildlife adding the native flannelmouth and bluehead suckers as Outstanding Remarkable Values (ORV) for the Lower Dolores.

A 2007 draft management plan only listed as an ORV the native roundtail chub, a species of special concern by Colorado Parks and Wildlife.

“The Final (Plan) issued nearly six years later abruptly adds two more native species as ORVs,” states the protest letter. “Scientific investigation in the six years since the Draft was issued, has made it clear the BLM had it right back in 2007 when only the roundtail chub was listed as a Native Fish ORV.”

DWCD believes the BLM failed to recognize scientific progress regarding native fish populations by the Dolores River Dialogue, a group working to find cooperative solutions for responsible use of the river between groups.

“This disrespect and disregard for the depth of the multiparty collaborative effort is at the heart of this protest,” writes Preston.

DWCD points out that the roundtail chub deserves OHV status because it is more abundant and a pool-dependent species that has kept a stable population despite predominate drought conditions since 2000. The flannelmouth and bluehead suckers require a wider variety of habitat and more flows, and are more rare, especially the bluehead sucker.

But in its final decision, federal land agencies said “the three species should be considered together” as ORVs and that more needed to be done to insure the survival of native fish populations.

“Although the DRD process appears to have made great progress in gathering information and ideas for future river management, few specific actions have been implemented to achieve enduring protections for this reach of stream,” the final plan states. “Serious legislative, or other actions could achieve protections similar, and possibly much broader, than those offered by WSR designations.”

A legislative proposal for the Lower Dolores River is to create a National Conservation Area in exchange for the BLM dropping the wild and scenic suitability status from McPhee Dam to Slickrock.

Amber Kelley, Dolores River coordinator with San Juan Citizen’s Alliance, heads up a legislative subcommittee studying the matter.

“Some stakeholders have concerns about wild and scenic status, while others want to make sure that river values have long term protection,” Kelley stated. “An NCA is a compromise in which Wild and Scenic consideration would be taken off the table, but important ecological and recreation values could still have long-term protection.”